Well, taking away the violence [which has not always remained non-lethal] what about just the very harsh and very vocal protests? I have seen both Phelps protests at Military funerals and Benham protests at Clinics up close and there frankly is ZERO difference.
If there is ZERO difference, then someone may be encouraged by this recent judgement to bring a similar suit against Benham. Assuming the case is presented similarly, etc., a jury would probably be well within its rights to issue a similar reward.
Perhaps what you're fishing for is this: In the Phelps case, the plaintiff didn't do anything wrong - his son had died, and he was going to his burial, and was subjected to this premeditated, organized hateful onslaught.
In the hypothetical above, if the plaintiff were a young woman who was actually going in for an abortion, a jury might be harder pressed to see their relative innocence. Getting an abortion at a walk-in clinic is plainly a willful, elective, lifestyle-related activity...attending the funeral of your child isn't.
That said, a plaintiff considering taking Benham to court would have an easier time with their case if they were visiting a Planned Parenthood for example, for a reproductive health issue unrelated to birth control. Imagine if you will, a woman with an STD looking for information or guidance on whether or not childbirth is something she should pursue.
Since the Benham crew probably doesn't stop to ask "Are you here to kill your baby?" before lighting into a patron, they're exposing themselves to just such a lawsuit. They probably deserve whatever the system doles out.